COUNTY OF
    OGLE,
    Complainant,
    )
    v.
    AC 91-45
    Dockets A & B
    (County No. 91—R—3.003)
    ROCHELLE DISPOSAL SERVICE,
    )
    (Administrative Citation)
    INC.,
    and CITY OF ROCHELLE,
    )
    ILLINOIS,
    )
    )
    Respondents.
    )
    MR.. DENNIS
    SCHUMACHER,
    STATE’S
    ATTORNEY
    AND
    MS. ROBBIN STUCK~,
    ASSISTANT
    STATE’S
    ATTORNEYS
    OF OGLE ~UNTY, APPEARED ON BEHALF
    07
    THE
    PETITIONER;
    MR.
    JORDAN
    GALLAGHER
    OF
    GALLAGHER,
    KLEIN, AND BRADY,
    APPEARED
    01
    BEHALF
    OF
    ROCH~LLE
    DISPOSAL
    SERVICES,
    INC.;
    AND
    MR.
    DENNIS
    HEWITT
    APPEARED
    ON
    BEHALF
    OF
    THE
    CITi
    OF
    ROCH~tT~V.
    OPINION
    AND
    ORDER
    OF
    THE
    BOARD
    (by
    J.
    C.
    Merlin):
    This action was initiated on Sept.abar 27, ~gg~ by the
    filing of an administrative citation (AC) by
    the
    County
    of
    Ogle
    (County).
    The
    AC was tiled pursuant to Section 31.1 of
    the
    Illinois Environmental Protection Act (Act).
    The authority to
    issue
    ACs was delegated to
    the
    County pursuant to Section 4(r)
    of
    the
    Act.
    (Ill. Rev. Stat. 1991,
    cli. 111 1/2, par. 1031.1 and
    1004 (r).)
    The AC charges Rochelle
    Disposal
    Services (Rochefle
    Disposal) and the City of Rochelle (City) with violation of
    •Section 21(0) (5)
    .~
    Both respondents filed a petition for review
    on October 11,
    1992,.
    Hearing was held in this matter on April
    29,
    1992.
    On June 4, 1992
    the
    Board
    issued
    en order denying
    Rochelle Disposal’s motion to be dismissed
    as
    a
    party
    to thiS
    action.
    In addition,
    the
    June
    4,
    1992
    Board
    order
    denied
    Rochelle Disposal’s motion for summary judgment.
    BACKGROUND
    The respondents are charged with lack of daily cover in
    1Section 21 of the Act was amended by Public Act 87-752,
    effective January
    1,
    1992.
    As a result, the two subsections
    enforceable through the administrative citation process have
    been
    changed froni 21(p) and 21(q)
    to 21(o) and 21(p)
    respectively.
    OI38-O3~3

    2
    violation of section 21(0) (5) of the Act.
    The landfill at which
    the alleged violation occurred is owned by the City.
    Disposal
    operates the landfill under a contract between it and the city.
    The alleged violation took place on August 2, 1991.
    Ogle County
    alleges that the inspector, Mr. Steve
    Rypkema,
    arrived
    at
    Rochelle Municipal Landfill 2 for a regular inspection
    at
    6:58
    A.)!. and found a lack of daily cover.
    In the AC, the
    County
    charged the respondents with only
    one
    violation
    and therefore
    assessed a penalty of $500.00 as provided for in Section 42(b) (4)
    of the Ac...
    ISSUE
    At hearing, Mr. Rypkema testified that when he arrived at
    the landfil
    site at 6:58 a.m., he found approximately 60—120
    feet of garbage uncovered in the “Daily Fill Area”.
    (Tr. at 10,
    17, and 29.)
    Sev~ra1photographs were tak.n by Mr. Rypkema at
    the site and were entered into evidence.
    (Cc~p.Group Zxh.
    4.)
    The
    photographs
    show
    piled
    garbage
    with
    what Mr. Rypkeaa
    described
    at
    hearing
    aS
    small
    patches
    of
    cover.
    (Cóap.
    Group
    Exh.
    4
    at
    12.6,
    12.7,
    12.8,
    12.9,
    12.10,
    12.11,
    and
    12.12.)
    Mr.
    Rypkema
    stated
    that
    when
    he
    was
    driving
    down
    to
    the
    area
    in
    question,
    he
    saw
    a
    bulldozer
    in
    the
    shed
    and it followed him down
    to
    the
    area.
    (Tr.
    at
    45
    and
    46.)
    Mr.
    Rypkema
    also
    testified
    that
    when
    be
    was ~at
    the
    site,
    he
    spoke
    with
    Mr.
    String
    who
    was
    filling
    in
    for
    the
    regular
    gate
    operator,
    Mrs.
    Bearrows.2
    .(Tr.
    at
    13.)
    Mr.Rypk.aa
    testified
    that
    Mr.
    String
    told
    him
    that
    the
    first
    garbage
    load
    to
    arrive
    on
    the
    day
    in
    question
    was
    the
    truck
    which
    arrived
    when
    Mr.
    Rypkema
    was
    already
    at
    the
    site.
    (Tr.
    at
    19
    and 36.)~’i(r.Rypkeaa
    also
    teótified
    that
    at
    approximately
    7:30
    a.m.
    Mr.
    Clyde
    Gelderloos,
    thern
    President
    of
    Rochelle
    Disposal
    Services
    Incorporated,
    arrived
    at
    the
    site..
    (Tr.
    at
    37.)
    Mr.
    Rypk.ma
    tutlri.d that
    be
    asked
    Mr.
    Gelderloos
    about
    the
    uncovered
    garbage
    and
    slid
    that
    it
    appeared
    that
    they
    where
    covering
    weekly instead
    of
    daily.
    (Tr.
    at
    38.)
    According
    to
    Mr.
    Rypkema,
    Mr.
    Gelderloos
    did
    not
    respond
    to the
    allegation.
    (Tr.
    at
    38.)
    Mr.
    Rypkema
    went
    on
    to
    testify
    that
    it
    would
    be
    normal
    for
    a
    landfill
    operator
    to
    remove
    the
    soil
    cover
    from
    the
    night
    before
    in order to receive
    more
    refuse.
    (Tr.
    at
    44
    end
    45.)
    Kr.
    Rypkema testified that during prior
    inspections,
    he could not
    remember a time
    when
    the
    daily
    cover
    was•
    removed prior to his
    7:00 a.m.
    inspe~.tion.
    (Tr. at 47 and 49.)
    Bov”ver,.he did
    testify that
    in
    the
    past
    be
    had
    seen
    the
    operato.~s remove
    the
    cover.
    (Tr.
    at 49.)
    When this occurred, the covering was pushed
    to the side of the work area or on top of the working face.
    (Tr.
    2No first name appears in the record for either Mr. String
    or
    Mrs.
    Bearrows.
    Uf38-O3L~

    3
    at
    49.)
    Mr.
    Rypkema
    went
    on
    to
    explain
    that
    be
    Could
    tell
    that
    the
    area
    had
    not
    recently
    been
    scraped
    because
    there
    was
    no
    soil
    piled
    up
    around
    the
    working area.
    (Tr.
    at
    49.)
    In
    addition,
    be
    testified that the area depicted in the photo marked 12.6 could
    not
    have
    been
    covered
    because
    if
    the
    cover
    had
    been
    removed,
    more
    soil
    would
    be
    mixed
    in
    with
    the
    garbage.
    (Tr. at
    120.)
    At
    hearing,
    Mr.
    Gelderloos
    testified
    for
    the respondents.
    He
    stated
    that
    he
    did
    not
    observe
    the
    area
    in
    question
    until
    after
    solid
    waste
    had
    already
    been
    received
    that
    day.
    (Tr.
    at
    55)
    However,
    he
    testified
    that
    it
    was
    his
    opinion
    that
    the
    area
    was
    properly
    covered
    the
    night
    before
    but that
    it
    was
    uncovered
    early
    on the morning
    in
    question
    to
    receive
    waste
    for
    the
    coming
    day.
    (Tr.
    at
    58.)
    Mr.
    Gelderloos
    testified
    that Mr. Ray
    Hartman,
    the
    operator
    responsible
    for
    covering
    the
    site,
    normally
    arrives
    at
    work
    between
    5:30
    a.m.
    and
    6.
    ‘(Tr.
    at
    59.)
    On the
    day
    in
    question,
    Mr.
    Hartman’s
    time card showed him as being
    at
    work
    at
    6.
    (Tr.
    at
    59
    and
    Reap.
    Each.
    1.).
    Mr.
    Gsldazloos
    teStified that normally, the daily cover would be
    removed
    and
    placed off to one side or on
    the
    side
    of
    the downhill slope
    toward
    the
    barrow
    pit;
    however,
    Kr.
    G.lderloos
    did
    not
    notice
    where the cover was placed on the day
    in
    question.
    (Tr.
    at
    60
    and 62).
    Mr~ Ray Hartman also testified for the respondents
    at
    hearing.
    Mr. Hartman
    stated that be likes
    to normally leave the
    shed
    area
    by
    6:15
    a.a.
    to
    go
    remove the
    daily
    cover.
    (Tr.
    at
    74.
    )
    He
    stated
    that
    there
    .is
    no
    normal
    time
    be
    removes the cover
    but
    that
    it
    must
    be
    done
    before
    the
    first
    truck
    arrives
    with
    solid
    waste.
    (Tr.
    at
    75.)
    Mr.
    Bartaan tstified that
    on
    August
    1•,
    1991,
    he
    covered
    the
    area
    before
    he
    left
    work.
    (Tr.
    at
    78.)
    Mr.
    Hartnaan
    testified
    that
    on
    August
    2,
    1991,
    he
    got
    to
    work
    et 6:00 a.m. and went down to the pit in
    the
    bulldozer to remove
    the cover~.
    (Tr. at 80)
    However, he ended up having to go back
    to the repair shop because of a leak in
    one
    of
    the hoses.
    (Tr.
    at 80 and Resp. Exh.
    2.)
    In contrast to Kr.
    Rypksma’s
    allegations,
    Mr.
    Bartman
    testified
    that
    he
    had removed
    the cover
    from the area before he went back to the repair
    shop.
    (Tr. at
    80.)
    Mr. Rartman also testified that it normally takes him
    twenty to twenty—five minutes to remove
    the cover and that it
    took him five or six minutes to fix the hose.
    Thus, be returned
    to the daily fill area in the bulldozer at about
    7:00.
    (Tr. at
    82 and 83.)
    Finally, Mr. Harthan testified that he could not remember
    where he piled the covering on the
    day
    in question.
    (Tr. at
    102.)
    Mr. Martman, when looking at complainant’s group exhibit
    4,
    photographs
    12.5
    and 12.11 could not identify where the daily
    cover had been piled.
    (Tr. at 102 and 103.)
    Mr. Hart*an
    testified that it would be hard to tell from the pictures where
    the daily cover material had been stacked because it mixes with
    O138-O3~5

    4
    the garbage
    and
    does
    not
    look
    like
    a
    pile
    of
    soil
    when
    removed.
    (Tr. at 104.)
    Instead, be testified
    it
    would
    look
    like
    piles
    of
    garbage.
    (Tr.
    at
    104.)
    DISCUSSION
    In
    its
    AC,
    the
    County
    charged
    the
    respondents
    with
    a
    violation of Section 21(o)(5).
    (AC at 1.)
    Section
    21(0)(5)
    prohibits any person from conducting
    a sanitary landfill which is
    required to have a permit,
    in such a
    manner
    as to
    leave
    uncovered
    waste remaining from
    a previous operating day
    or
    at
    the
    conclusion of an operating day
    unless
    the facility’s
    permit
    50
    allows.
    The
    Respondents
    are
    permitted
    pursuant
    to
    Section
    21(d) of
    the
    Act.
    The operating
    permit
    issued to
    the
    City
    of
    Róchelle
    does
    not
    allow
    for
    uncovered
    refuse at
    the and
    of
    an
    operating
    day.
    In fact, the
    permit
    specifically states in
    the
    Standard
    Conditions section that ~wastemust be compacted in
    layers
    and
    covered daily with six inches of suitable
    material.”
    (Camp.
    Each.
    2 at 3)
    Therefore,
    the
    sole issue is whether or
    not
    daily
    cover
    was applied.
    In the case at hand, there
    was
    extensive
    testimony
    from
    each side regardingthe issue
    of
    cover.
    Mr.
    Hartean
    testified
    that
    he
    bad
    removed
    the
    cover
    to
    begin
    rlc*iving
    new
    waste,
    and
    Mr.
    Rypkema
    testified
    that
    in
    his
    opinion
    no
    cover
    was
    ever
    applied
    to
    the
    area in question.
    The
    photographs
    taken during
    the
    inspection
    and.
    entered
    as
    Complainant’s Group Exhibit
    4 show
    a large pile of un-compacted garbage with little or no soil
    coverage.
    It
    is
    obvious
    from
    the
    photographs that very
    little,
    if
    any,
    dirt
    is mixed in with the garbage at the
    site.
    Additionally, both
    Mr.
    Hartaan
    and
    Mr.
    Gelderloos
    testified
    that when the daily cover is removed, a pile of dirt with garbage
    mixed in is created.
    However, Mr.
    Hartman
    was unable
    to explain
    where the piles of daily cover were placed on the
    day
    in question
    and no piles were
    shown
    in
    the
    photographs.
    In addition, Mr.
    Gelderloos testified that
    he could not
    remember where the
    pile of
    daily cover was located on the day
    of the alleged viOlation.
    The Board, after careful consideration,
    is
    persuaded
    by
    Mr.
    Rypkezna’s
    testimony
    and
    the
    photographs taken
    at
    the inspection
    which
    corroborate
    Mr.
    Rypkema’s
    teFtimofly.
    The
    Board
    believes
    that if daily cover had been applie.. and
    later
    removed
    that
    the
    garbage shown
    in
    the photogr~bs
    would be
    more cozpaàted and dirt
    would
    be
    mixed
    throughout.
    At.litionally,
    the
    pile
    of
    dirt
    from
    the
    removal
    should
    have
    been
    visible.
    For
    the
    reasons
    stated
    in
    the
    above
    opinion,
    the
    Board
    finds
    that the respondents, the City of Rochelle and Rochelle Disposal
    Inc.,
    have
    violated
    Section
    23(o)
    (5)
    of
    the Act.
    Accordingly,
    0138-03136

    5
    the respondents are jointly and serverably liable for a penalty
    of
    $500.00.
    This opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    1.
    Respondents, the City of Rochelle and
    Rochelle Disposal Inc., are
    hereby found to
    have violated
    Ill. Rev. Stat.
    1991,
    oh. 111
    1/2, par. 2l(o)(5).
    2.
    Within 30 days of this order, the respondents
    shall pay the sum of five hundred dollars
    ($500.00) by check or money order
    to
    the
    Ogle
    County Treasurer.
    The
    payment shall be
    mailed to:
    Ogle
    County
    Treasurer
    Ogle
    County
    Courthouse
    P.O. Box 40
    Oregon, Illinois 61061.
    Respondents shall also
    write
    their Federal
    Employer
    Identification.
    Number
    or Social
    Security
    Number on
    the
    certified
    check
    or
    money
    order.
    Any such penalty not paid within
    the
    time
    prescribed
    shall
    incur
    interest at the rate
    set forth in subsection
    (a) of Section 1003
    of the Illinois Income Tax Act,
    (Ill. Rev.
    Stat.
    3991,
    ch. 120, par.
    10—1003), as now or
    hereafter amended, from the date payment is
    due
    until
    the date payment is received.
    Interest shall not accrue during the pendency
    of
    an
    appeal
    during
    which
    payment
    of
    the
    penalty has been
    stayed.
    3.
    Docket
    A
    in this matter is
    hereby
    closed.
    4.
    Within 30 days of this order,
    the
    County
    shall file a statement of
    its hearing costs,
    supported by affidavit, with
    the
    Board and
    with service
    on
    the
    respondents.
    Within
    the
    same
    30
    days,
    the
    Clerk
    of
    the
    Pollution
    Control
    Board
    shall
    file
    a
    statement
    of
    the
    Board’s
    costs,
    supported
    by
    affidavit
    and
    with
    service
    upon
    the
    respondents.
    Such
    filings
    shall
    be
    entered
    in
    Docket
    B
    of
    this
    matter.
    0138-031+7

    6
    5.
    Respondents are hereby given leave to file a
    reply/objection
    to
    the
    filings
    as
    ordered
    in
    paragraph
    4
    of
    this
    order
    within
    45
    days
    of
    this order.
    IT
    IS
    SO
    ORDERED.
    Section 41 of the Environmental Protection Act
    (Ill.Rev.Stat. 1991, Ch Ui
    3/2, par.
    1041)
    provides
    for
    appeal
    of final orders of the Board within 35 days.
    The
    rules of the
    Supreme Court of
    Illinois establish filing requirements.
    (But
    see also 35
    Ill.
    Adm.
    Code
    101.246,
    Motions
    for
    Reconsideration,
    and Castenada
    v. Illinois Human
    Riabte commission
    (1989), 132
    Ill. 2d 304, 547 N.E.2d
    437~)
    I, Dorothy K.
    Gunn,
    Clerk
    of
    the Illinois Pollution Control
    Board,
    hereby
    certif__that
    the
    above ppjnion and
    order was
    adopted
    on
    the
    __________
    day
    of
    by .a vote of
    __________________
    Control Board
    0138-031+8

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